DAQ-2024-011246

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-1069-24
Site ID 13031 (B5)

Tom Wiscomb, Senior Environmental Analyst
PacifiCorp
1407 West North Temple, Suite 310
Salt Lake City, UT 84116

Dear Mr. Wiscomb:

Re: PacifiCorp (Lake Side Plant) – Pretest Protocol for Carbon Monoxide (CO), Oxygen (O2),
and Nitrogen Oxides (NOx) Relative Accuracy Test – Utah County

The Utah Division of Air Quality (DAQ) reviewed the pretest protocol for the PacifiCorp Lake
Side Plant dated October 14, 2024. The proposed test shall be performed under the following
conditions:

Lake Side Plant’s monitoring system to be certified:

Point Source Channel Manufacturer Model # Monitor SN
CT11
CO Not Provided (NP) NP NP
NOx NP NP NP
O2 NP NP NP
CT12
CO NP NP NP
NOx NP NP NP
O2 NP NP NP
CT21
CO NP NP NP
NOx NP NP NP
O2 NP NP NP
CT22
CO NP NP NP
NOx NP NP NP
O2 NP NP NP

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DAQC-1069-24
Page 2

Mostardi Platt will conduct a relative accuracy/performance specification test on the Lake Side
Plant’s continuous monitoring system.

Relative accuracy must be determined in the units of the emission standard or equivalent units of
the emission standard, i.e., tons/year shall be tested in pounds/hour.

The DAQ understands that testing will be conducted as follows:

Test Date Point Source Parameter EPA Reference Method
December 9-12,
2024
CT11, CT12, CT21,
and CT22
CO, O2, and NOx
RATA Method 3A, 7E, 10

• Reference Method 3A - Determination of Oxygen and Carbon Dioxide Concentrations
in Emissions from Stationary Point Sources – (Instrumental Analyzer Procedure) as
outlined in 40 CFR 60 Appendix A.

• Reference Method 7E - Determination of Nitrogen Oxide Emissions from Stationary
Point Sources - (Instrumental Analyzer Procedure) as outlined in 40 CFR 60 Appendix
A.

• Reference Method 10 - Determination of Carbon Monoxide Emissions from Stationary
Point Sources – (NDIR Instrumental Procedure) as outlined in 40 CFR 60 Appendix A.

• Zero drift and calibration drift checks are required at the beginning and end of each
run.

• Deviations - The Director or the representative of the Director must be notified of and
approve deviations of the Reference Method test. Any deviation from these conditions
without approval from the DAQ may constitute rejection of these tests.

Acceptance of a protocol does not relieve the owner/operator and the testing contractor
from strict adherence to all applicable EPA methods, DAQ policies, Utah Air Quality
Rules (UAQR), and methods approved by the Director. Any deviation from EPA
methods, DAQ policies, UAQR, and methods approved by the Director must be
addressed separately and express written consent given prior to commencement of
testing.

• Field data (Point Source emission data and test data) shall be turned over to the DAQ
in a timely manner for review.

• The Director will determine the relative accuracy of each monitoring system based on
Point Source continuous emission monitoring data and test data acquired by the staff
member of the DAQ during the test.

DAQC-1069-24
Page 3

• All test reports must be submitted to the Director not later than 60 days after
completion of the test.

• The test report shall include all raw calibration data and raw emission data with date
and time stamps.

Relative accuracy test reports must contain:

1. Point source continuous monitor, channel, manufacturer, and serial number.

2. Raw stack test data and continuous monitor data with date and time stamps.

3. Emission data reported in concentration (ppm or %) and units in the applicable
emission limit.

The DAQ requires that all test reports include a statement signed by a responsible official
certifying that:

1. Testing was conducted while the Point Source was operating at the rate and/or
conditions specified in the applicable approval order, operating permit, or federal
regulation.

2. During testing, the Point Source combusted fuels, used raw materials, and maintained
process conditions representative of normal operations, and operated under such other
relevant conditions specified by the Director.

3. Based on information and belief formed after reasonable inquiry, the statements and
information contained in the report are true, accurate, and complete.

Should you have any questions concerning this matter, contact me at [phone] or by email
at [e-mail].

Sincerely,

Rob Leishman, Environmental Scientist
Major Source Compliance Section

RL:jl

cc: Utah County Health Department
Mostardi Platt
* $ . # ( ) - — / @ G v A ? A C @ E w D ? ˜
Rob Leishman Jr